G.R. No. 184601 - People vs. Malicdem y Molina

On September 12, 2002, an information for the crime of murder was filed against appellant Marcial Malicdem y Molina.
The alleged crime occurred on or about August 11, 2002, in the evening at Brgy. Anolid, Mangaldan, Pangasinan, where the accused, armed with a bladed weapon, reportedly attacked Wilson S. Molina with intent to kill and with treachery.
The charge was filed in violation of Article 249 of the Revised Penal Code as amended by RA 7659.

The accused was arraigned on October 17, 2002, where he pleaded not guilty.
Trial on the merits ensued with the prosecution presenting its witnesses: Dr. Ophelia T. Rivera, Bernardo Casullar, Joel Concepcion, Felipe Molina, and Maricon Nicolas.
The defense presented witnesses including the accused himself and his wife, Anabel Malicdem, asserting a claim of self-defense.

According to the prosecution testimonies (Bernardo and Joel), on the night of August 11, 2002, after having dinner near an artesian well, the accused appeared intoxicated and inquired about his godson, Rogelio Molina.
When the accused approached the group, he allegedly suddenly embraced Wilson and lunged with a six-inch knife, inflicting a fatal stab wound on Wilson’s chest.
During the ensuing melee, Bernardo was injured by the knife, Joel intervened by engaging in a physical struggle with the appellant, and Francisco Molina, the father of Rogelio, was also stabbed.
Wilson was later rushed to the Region I Medical Center, where he was declared dead on arrival.

Dr. Ophelia T. Rivera, in her post-mortem report, documented multiple wounds on Wilson S. Molina including stab wounds and abrasions.
The findings attributed Wilson’s death to cardiorespiratory arrest secondary to hypovolemic shock due to stab wounds.

The defense narrative, presented by the appellant and his wife Anabel, recounted that they were initially at home attending to household matters before going out to search for the missing godson, Rogelio.
On their way home, they encountered Bernardo, Joel, and Wilson near the artesian well where the accused's inquiry about Rogelio led to a series of altercations.
According to their account, following an altercation that began with an alleged bottle-throwing incident and subsequent fistfights, self-defense was invoked when Wilson allegedly drew a knife.
The defense claimed that during the struggle for the knife, the fatal injury was inflicted accidentally or in self-defense.

The Regional Trial Court (RTC) rendered its decision on July 31, 2006, convicting the accused of murder beyond reasonable doubt, emphasizing that the act was committed without self-defense and with the presence of treachery.
The RTC noted inconsistencies in the testimonies of the appellant and his wife, which undermined the self-defense claim.
The RTC sentenced Marcial Malicdem y Molina to reclusion perpetua and ordered him to pay actual, civil indemnity, moral, and other damages.
The Court of Appeals later affirmed, with modifications, the RTC decision, specifically revising the award for exemplary damages.

The appellant argued that the trial court gravely erred in its interpretation of facts and in giving credence to the prosecution’s evidence.
He contended that minor inconsistencies in his and his wife’s testimonies did not affect their overall credibility, thereby asserting that his claim of self-defense should have been given due weight.
The appellant claimed that the version of events presented by the prosecution was highly incredible, given the absence of any grudge between him and the victim prior to the incident.

Whether the accused’s act, as described by the prosecution, constitutes murder committed with qualifying circumstances, particularly treachery.
Whether the self-defense claimed by the appellant is legally sustainable given the evidence and inconsistencies in the testimonies.
Whether the inconsistencies in the defense testimonies are sufficient to undermine the credibility of the self-defense claim.
Whether the trial court’s findings regarding the sudden and treacherous nature of the assault were supported by the evidence.
Whether the award and modification of damages, including exemplary damages, are in accordance with the established jurisprudence on criminal civil liability in homicide cases.